July 11, 2022
I appreciate the opportunity to comment on the Final Environmental Impact Study on the Pennsylvania Station Area Civic and Land Use Improvement Project.
New York State’s plan to reconstruct and expand Penn Station through a complete redevelopment of the blocks surrounding the station will have one of the most transformational effects on our community for the next century. Nearly everyone agrees that Penn Station is in desperate need of an overhaul and it would be fiscally prudent to take advantage of federal infrastructure funding while it is available. I am thankful for the hard work of our local elected officials, Community Boards Four and Five, and all the members of the Community Advisory Committee Working Group which has resulted in improvements to the plan. However, there are still many areas of the plan in strong need of change in order for a plan to truly benefit both our regional transportation infrastructure and the surrounding community. The following comments are my prime areas of concern.
I appreciate the reduction in commercial space in favor of greater residential development. When the demand for class-A office returns, the areas around major transportation hubs such as Penn provide an excellent location, yet I believe the heavy reliance on commercial development remains a financial risk in light of other options.
Our city and region are currently facing a housing crisis driven by a shortage of new residential development. This plan can help meet that demand by including greater requirements for residential development. The current plan only requires housing at site 1A, leaving sites 1B, 4 and 8 as only having the option of residential development. This leaves a plan where the final amount of housing may turn out to be minimal, and potentially non-existent, as the only required housing location, site 1A, would not be developed if an alternative other than the southern expansion is selected. A guarantee for new affordable housing must be included in this plan by requiring residential development on sites outside the southern expansion area.
Displacement of Residents and Small Businesses
I am against eminent domain that would displace residents and businesses. The state must thoroughly pursue a path to increase station capacity without displacing local residents.
If the southern expansion plan moves forward in the end, new housing on another site should be developed first with current residents having the first shot at moving there. Any residents in current affordable units must be supplied with an equivalent affordable unit with the same or better terms. Long time residents facing displacement have concerns about what they are facing, including potential timelines, options and compensation. Greater efforts must be made to ensure residents have all the information and assistance they need.
Governance Oversight and Accountability
This multi-agency plan with a multi-decade timeline is currently far too fractured to succeed in a manner that provides transparency and accountability to the public. The dysfunction of three commuter rail lines (Long Island Rail Road, New Jersey Transit and eventually Metro North) and a long distance railroad (Amtrak) all utilizing one station is unacceptable for a 21st century rail station that is the hub of our country’s largest metropolitan area. I urge Governor Hochul to appoint a singular head to coordinate and manage the entire project. This person should have the power to break through a singular agency’s self-interests and also be held accountable for promises made to riders and the local community. This project will require great coordination between work occurring above and below ground as well as providing regular information and opportunities for public input, a requirement that calls for a single point of accountability.
Madison Square Garden
The current station is the result of one of the worst planning decisions ever made in this city: razing the architectural marvel that was the former Penn Station and replacing it with the claustrophobic underground maze we deal with today. We will be making an equally catastrophic decision by ignoring the elephant on top of it all, Madison Square Garden. The continued presence of MSG blocks the construction of the grand train hall our city deserves. MSG support beams restrict realigning station tracks and platforms and also heavily reduce the viability of a through-running option. Any public realm improvements will be negatively impacted due to the loading operations of MSG and the disruptive presence of trucks that regularly park along Eighth Avenue taking both street and sidewalk space. The goal of a world class, welcoming and efficient transportation hub cannot be fully met until MSG is moved.
I am pleased to see that recommendations from the CACWG to provide social services on site are included. I am concerned that these services have been delegated to sites that would only be developed if the southern expansion were to occur. An alternative proposal for these services must be included so that they are guaranteed if the southern expansion is not selected.
Public Realm Improvements
The creation of a public realm task force is a critical part of this plan and its success will be critical to the cohesiveness of the neighborhood and upgraded station. I share the concerns raised by Community Board Four regarding the funding mechanism for the public realm fund. An arrangement that guarantees funding, such as setting a fixed proportion of PILOTs, must be explored.
The sidewalks surrounding Penn Station are overcrowded and an increase in station capacity combined with new development will exacerbate that. Pedestrians must be the top priority in any new street designs and pedestrian space must not be impeded by other needs. All building frontage in the area should be active, avoiding wide lobby entrances or dead space alongside building entrances. All building operations such as loading and garbage removal should take place in buildings’ interiors.